Inside the FCBF–CBP Roundtable: What Customs Brokers and Freight Forwarders Should Know

FCBF leadership sat down with CBP's Office of Trade, led by Executive Assistant Commissioner Susan Thomas, to discuss the current state of CBP operations, IEEPA refunds, Foreign Trade Zones, bonded facilities, and the Electronic Export Manifest rollout. Here's what the conversation means for brokers, forwarders, and importers.

As an FCBF officer and Secretary of the Florida Customs Brokers and Forwarders Association, I had the opportunity to participate in a recent roundtable between FCBF leadership and CBP's Office of Trade — including Executive Assistant Commissioner Susan Thomas.

The discussion covered several issues that directly affect the daily work of customs brokers, freight forwarders, NVOCCs, and importers: the current state of CBP operations, IEEPA-related refunds, Foreign Trade Zones, bonded facilities, and the status of Electronic Export Manifest (EEM) implementation.

FCBF leadership met with CBP's Office of Trade to discuss CBP operations, IEEPA refunds, Foreign Trade Zones, bonded facilities, and Electronic Export Manifest implementation. Below is a plain-language readout of what each topic means for trade operators on the ground.

Why This Roundtable Matters

Policy decisions made inside CBP show up at the dock, the terminal, and the inbox of every broker and forwarder within weeks. When FCBF participates in these conversations, the goal is to make sure CBP hears what is actually happening in the field — slow refund processing, FTZ admission questions, bonded warehouse capacity, and export filing realities — and to bring back accurate information to the trade community before rumors fill the gap.

FCBF continues to actively represent the interests of customs brokers, freight forwarders, and trade professionals by participating in discussions with CBP and partner government agencies. The willingness of CBP's Office of Trade leadership, including EAC Susan Thomas, to engage at this level of detail is a meaningful signal to the industry.

Key Takeaways from the Discussion

1. The Current State of CBP Operations

CBP continues to balance enforcement priorities with throughput pressure at major ports. For brokers and forwarders, that means staying close to release timelines, exam coordination, and PGA holds — and making sure shipment-level information is clean before it reaches CBP, not after.

2. IEEPA Refunds and the CAPE Process

Refunds tied to International Emergency Economic Powers Act (IEEPA) duties remain a major topic. CBP's Consolidated Administration and Processing of Entries (CAPE) mechanism is how qualifying refunds move. Importers of record who paid IEEPA duties on potentially eligible entries should be working with their licensed customs broker to identify entries, confirm ACE and ACH refund setup, and prepare the CAPE Declaration accurately. Mistakes — missing entry numbers, unconfigured ACH, or ineligible entries included in the submission — are the most common reasons refunds stall.

If you paid IEEPA duties and have not yet reviewed your entries for CAPE eligibility, that review is time-sensitive. Coordinate with your customs broker now rather than after deadlines pass.

3. Foreign Trade Zones (FTZs)

FTZs continue to be an important tool for importers managing duty deferral, inverted tariff scenarios, and consolidated distribution. The conversation covered operational questions FTZ operators and users face — admission documentation, weekly entry procedures, and how FTZ activity intersects with current tariff exposure. For NVOCCs and forwarders supporting FTZ users, the takeaway is to keep the broker, the zone operator, and the importer aligned on what is being admitted, manipulated, and withdrawn.

4. Bonded Facilities

Bonded warehouses and CFS facilities continue to play a critical role for cargo that needs time before entry — whether for documentation, financing, or operational reasons. Topics raised included capacity, operational compliance, and the interaction between bonded movement and CBP exam coordination. Brokers and forwarders should make sure their clients understand what bonded status does and does not do — it defers entry, but it does not eliminate the eventual filing, classification, and duty obligation.

5. Electronic Export Manifest (EEM) Implementation

EEM has been a long-running modernization effort to bring U.S. export manifest filing into a fully electronic, harmonized system across ocean, air, rail, and truck. Implementation status, system readiness, and how the rollout will affect carriers, NVOCCs, and forwarders were discussed. For trade operators, the practical advice is to monitor EEM pilot updates, confirm internal system readiness, and make sure export-side data quality is treated with the same discipline as import-side ACE filings.

What Brokers, Forwarders, and Importers Should Do Now

1. Review IEEPA-impacted entries with your licensed customs broker and confirm whether any qualify for refund under the CAPE process — including ACE and ACH refund setup.
2. If you use or operate an FTZ, confirm that your admission and withdrawal documentation reflects current tariff and PGA requirements, and that the broker, zone operator, and importer are aligned.
3. Review bonded warehouse and CFS arrangements to make sure entry, classification, and duty planning is in place before goods are withdrawn — not after.
4. Monitor EEM rollout updates and assess internal readiness on the export side, especially if your operation files outbound manifests.
5. Stay subscribed to FCBF and CBP communications. Policy detail changes faster than most operating teams can track without a structured intake.

FCBF's Role

The Florida Customs Brokers and Forwarders Association represents customs brokers, freight forwarders, NVOCCs, and trade professionals across Florida and beyond. Engagements like this roundtable are how the industry's operational reality reaches CBP's policy and operations leadership — and how accurate information flows back to members. We appreciate the opportunity to collaborate and engage in meaningful conversations that support the trade community.

If you would like to discuss how any of these topics — IEEPA refunds, FTZ activity, bonded facilities, or EEM — apply to your operation, AP Customs is available to help review your process.